Social violence

New Brunswick is generally considered a peaceful province, with a relatively low crime rate compared to the national average. In the past, as in other jurisdictions, there have been outbreaks of vigilante behaviour, when individuals and communities take the law into their own hands, as well as peaceful disputes and economically and politically-motivated violence over access to resources and employment.

In the early 1840s the colony experienced election riots and lumberjacks in Dalhousie and Campbellton attacked the stores of local merchants. Until 1871 British troops were in garrison in the province and available to aid the civil power. This function was taken over by police forces (which first appeared in the 1840s and 1850s) and the militia.

The examples below, a sample of incidents of social violence in New Brunswick, remind us that nostalgic interpretations of the past as ‘the good old days’ are a distortion of reality. In many cases, individuals and communities were reacting to fear of losing jobs, political power or rights. As the first example indicates, the Loyalist colony of New Brunswick was born in political unrest which generated an authoritarian legal response.

In the late 20th century, riot police, tear gas and police dogs were deployed against forestry and fishery workers and even parents protesting education cutbacks. RCMP actions in handling demonstrators at Saint-Saveur and Saint-Simon in 1997 resulted in one hundred and seventy official complaints which included excessive use of force and detention, intimidation, verbal abuse, lack of adequate medical treatment, property damage and the use of roadblocks to deny citizens access to their homes.

The RCMP riot squad, which it called ‘the Special Unit,’ was equipped with riot sticks and shields and tear gas launchers. The unit included an emergency response team armed with precision rifles and hand guns. On these occasions the RCMP also gathered ‘intelligence’ by videotaping demonstrators. In recent years police tactical units have been deployed at or near peaceful demonstrations in Saint John and Fredericton.

Saint John 1785: First political riot, first anti-sedition law

In the late 19th and early 20th centuries, history textbooks, newspaper editorials and public commemoration of the past projected a romanticized image of the Loyalist refugees from the American Revolution. Much of this rhetoric emphasized that the Loyalists bequeathed to Canada a culture of deference and respect for lawful authority.

In reality, the American refugees who arrived at Saint John in the 1780s were not always unified politically and socially. This was revealed in the faction-driven politics of New Brunswick’s first election in 1785, which coincided with its first political riot. This event, as explained in detail by New Brunswick historian David Bell, was followed by "the most repressive piece of legislation ever enacted in New Brunswick."

During 1783 several thousand Loyalist refugees arrived at the mouth of the Saint John River in what was then northern Nova Scotia. They disembarked at a pre-existing settlement of New England traders and fisherman called Parr-town. Over the next two years a new British colony, New Brunswick, was created in northern Nova Scotia and Parr-town was incorporated, with a royal charter, as the city of Saint John.

Most of the Loyalists who ended up in the Saint John area were from New York, New Jersey and Connecticut but the elite 'agents' who enjoyed connections with New Brunswick's first governor, Thomas Carleton, were New Englanders. Over the course of 1783 six major transport fleets delivered refugees to the mouth of the St. John River.

Disputes and delays in the granting of town lots and farm lots in interior lowered morale among the heterogeneous Loyalist population. An attempt by fifty five 'genteel' Loyalists to acquire a disproportionate share of land provoked protests in New York. The controversy spilled over into Saint John’s first newspapers. The creation of New Brunswick in 1784 out of Nova Scotia was a potential set back for the protestors as it benefited the elite, but they did not openly oppose it.

In 1785 Parr-town and the neighbouring community of Carleton were merged and incorporated as the city of Saint John, providing rank and file Loyalists with a degree of local government. The colony's governor called a general election for the fall of the year and in Saint John the earlier political tensions resurfaced.

Opposition to the elite was based in the Lower Cove area of Saint John; their opponents were identified with Upper Cove (the Market Slip area). During the polling (elections at this time lasted several days) a mob of Lower Covers surrounded and attacked Upper Cove supporters at Mallard’s tavern. British troops were called out to restore order and a number of rioters were arrested. The election continued and in Saint John the victory went to the Lower Covers.

The government ordered a recount of the votes, prompting a series of petitions to the authorities in Fredericton, asking that the new legislature be dissolved. Rather than act on the petitions, the legislature passed a law which made petitions to the government bearing more than twenty signatures punishable by a heavy fine and jail term. Two newspaper publishers and four citizens who persisted in presenting a protest petition were arrested, charged, convicted and fined. As the events of 1785 indicate, the Loyalist colony of New Brunswick was founded in an atmosphere of dissent and repression.

Saint John 1849: The Orange vs. the Green

During the 1840s Saint John, Portland (a separate town which was amalgamated with Saint John in 1889), Fredericton and Woodstock all experienced ethnic and/or sectarian violence, stemming from tensions between Irish Catholics (many of them immigrants) and the Protestant majority. By 1851 nearly half of Saint John's population had been born in the British Isles and most immigrants were Irish.

A series of fights and riots in the Saint John area revealed not only the weakness of local policing, but also the intensity of ethnic identities. In 1847 at Woodstock, Carleton county, tensions between Irish Catholics and area members of the Loyal Orange Association (LOA) left at least ten dead. The Orangemen, who organized many lodges across the colony, were a fraternal society based on loyalty to the British monarchy and anti-Catholicism.

Expecting an armed Orange church parade to return to the town, Catholics gathered with guns, axes, clubs and scythes. In the aftermath of the fighting at Woodstock, no Protestants were arrested and nearly ninety Catholics were charged. Of forty-nine men tried, thirty-five were convicted.

A riot at Fredericton, the colony’s capital, was more a series of assaults and fights. One Catholic was fatally wounded and although a coroner’s jury named the assailant he was not prosecuted. As at Woodstock, no Orangemen were charged but thirty-four Catholics were indicted by a grand jury and fourteen imprisoned.

The first recorded incident of sectarian violence in Saint John took place in 1839. Over the next decade as the local Irish Catholic population grew the clashes multiplied in frequency and intensity. The first major incident took place on July 12, 1842, the LOA's annual celebration of the Battle of the Boyne. In subsequent years July 12, March 17 and the Christmas season were marred by assaults, gunfire and a number of murders.

It was rare for Protestants to be arrested. A violent encounter on July 12, 1847 left no official death toll, but rumours of unreported fatalities. Historian Scott See estimates that up to ten thousand New Brunswickers, many of them descendants of Loyalists, had joined the LOA by the late 1840s.

On July 12, 1849 a parade of Orangemen, many of them from surrounding rural counties, attempted to march through the largely Catholic immigrant waterfront neighbour of York Point. At its head was an Orangeman mounted on a white horse, representing King William of Orange, who had defeated the Stuart forces at the Battle of the Boyne in 1690.

They were returning from the Indiantown area of Portland where they met brethren from upriver. The Orangemen carried swords, pistols and muskets. The mayor feared serious violence if the parade reached Dock Street where Catholics had erected a green arch of tree boughs. At this time Saint John lacked a professional police force.

Unable (or unwilling) to separate the two sides, the civic authorities and the small garrison of British soldiers waited south of the Catholic 'line of battle.' A serious riot developed in which with rocks, bricks and firearms were used. Up to a dozen were killed and many more wounded, making the York Point riot the most serious outbreak of collective violence in New Brunswick’s history.

At this time the economy, the political system and the legal system were dominated by the Protestant majority, which also included immigrants from Britain. In contrast to previous incidents the authorities issued warrants for Catholics and Protestants in nearly equal numbers. Yet all the Protestant suspects either had their charges dropped or were acquitted; two Roman Catholics who had been sent to trial were acquitted.

The 1849 outbreak had two immediate impacts: Saint John was given a more professional police force and all 'sectarian' parades were banned for a generation. Years later, Dock Street site of the battle, was renamed St. Patrick Street in honour of Irish immigrants.

Caraquet 1875: Defending denominational schools

Religious and ethnic identities were strong in 19th century New Brunswick, and often connected to class tensions. The Common Schools Act of 1871 was the most controversial provincial law of the late 19th century, and resulted in the loss of two lives, a highly-publicized trial and a political settlement to a thorny political issue.

The law was an attempt to set up a free, non-sectarian system of public schools. Catholics in New Brunswick, who faced the loss of funding for separate schools, opposed the law in the courts and on the political level. As the minority struggled for its publically-funded schools, the provincial government fought the 1872 provincial election on anti-Catholic themes.

The law was aimed at separate religious schools, not French-language schools, but Acadian communities felt most vulnerable. After the election supporters of common schools in the provincial legislature were isolated to three heavily Acadian counties. Catholics began to refuse to pay their taxes in protest, leading to arrests and the seizure of property.

Early in 1875 a conflict developed between the Acadian majority and the English minority in the parish of Caraquet in Gloucester county. Caraquet, now site of le Village Historique Acadien/the Acadian Historical Village, was a small community dominated by the fishery. The events of 1875 also revealed the community's economic tensions.

When village officers whose authority was not recognized by the French-speaking majority attempted to call a public meeting to impose the local school tax, the meeting was broken up. The protestors then attempted to intimidate various members of the community to withdraw their support from the school tax. At one point a boisterous crowd demanded a gallon of liquor from a local store.

In the aftermath of these events religious and ethnic tensions simmered. Acadian frustrations focused on a local anglophone merchant who was also a member of the provincial legislative council. That individual, Robert Young, had opposed the Common Schools Act but as a member of the government and a local merchant he was a logical target of resentment.

Young, whose family had been threatened, refused to communicate with the demonstrators and arranged for warrants to be issued for the arrest of the "rioters." This task fell to the county sheriff who was accompanied by four constables and four special constables. A number of arrests were made and the authorities made the irregular decision to enroll additional militia members from a neighbouring anglophone community in another county. The legal status of these armed volunteers was uncertain. Meanwhile a number of Caraquet men involved in the earlier events gathered at the home of André Albert.

When the arresting party arrived with arrest warrants, a number of men took shelter in Albert’s attic. The men aiding the sheriff were all outsiders; one witness at a coroner’s inquest referred to them as "the strangers." Panic ensured when men armed with rifles and bayonets entered Albert’s house, pointed a gun a woman and were startled by a noise from above.

As a Crown witness later testified, one of the deputies fired into the ceiling to intimidate the men above as the occupants of the attic blocked access to the upper floor. In response someone discharged a gun from the attic. What happened next is not clear because of conflicting testimony and the confusion of a gun fight in close quarters. John Gifford, one of the sheriff’s party, was killed outright and Louis Mailloux, one of the defenders, was mortally wounded.

Gifford was a twenty-two year old resident of Newcastle. The remaining men surrendered and were marched, suffering from the winter weather, to jail in Bathurst to await trial. Fearing an attack on the jail, a magistrate requested the militia to protect the facility with field artillery. The authorities also called out fifty militia infantrymen.

The inquest on Gifford's body named nine Caraquet men as being involved in his death; these individuals were subsequently charged with murder. No one was charged with the death of Mailloux. Others were charged with rioting but released on bail. The grand jury indicted nine men for murder and eight of the same men for riot.

A further ten Acadians were indicted for rioting. Typical of serious offences, the cases were prosecuted by the attorney general who happened to be the premier of New Brunswick (and author of the 1871 school law). Compared to similar trials in the 1840s the petit jury that convicted nine men of illegal assembly (not rioting) was fairly representative of the community, containing Catholics and francophones.

This was in contrast with the jury for the murder case, which contained no Catholics. The chief counsel for the defence blamed the entire affair on Young (who was a non-elected member of the government). The premier remarked in court that "school matters had nothing to do with the riot."

This was in many respects a political prosecution and a legal defence fund collected money from New Brunswick and Quebec. Provincially the school issue pitted Protestants against Catholics but in Gloucester county linguistic identities were paramount. By late 1875 one of the rioters, Joseph Chiasson, had been convicted of murder and several of his co-accused had agreed to plead to involuntary manslaughter.

The defence counsel raised various objections and in 1876 the Supreme Court of New Brunswick upheld the earlier rioting convictions but quashed the murder and manslaughter convictions. The men held for rioting, who had already served months in jail, were released. The result, according to historian George Stanley, was an understanding by political leaders not to inflame public opinion over the issue. The Caraquet riot and trials became part of the collective memory of New Brunswick’s Acadian minority. A political agreement allowed the Catholic minority to enjoy certain privileges, but not the full rights that their leaders had demanded.

The Saint John Streetcar Strike 1914: Striking back At monopoly

The history of labour relations in Canada, especially before the advent of institutionalized collective bargaining by the mid 20th century, was characterized by occasional violence.

Public opinion was often an important factor in determining the outcome of these struggles, especially when large industrial or business enterprises were perceived as monopolies that threatened the public interest. The St. John Railway Company was one of these unpopular enterprises. The 1914 streetcar strike and riot, which took place just weeks prior to the outbreak of World War I, has been studied by historian Robert Babcock.

In Saint John the privately-owned streetcar company had generated controversy for more than a decade, refusing to issue workingmen's tickets that were standard in other cities and refusing to extend suburban lines to the satisfaction of much of the public. Many of the leading shareholders in the company were local business people.

In 1913 Saint John’s longshoremen staged a successful strike but hundreds of sawmill workers were locked out for trying to organize a union. In 1914 skilled tradesmen secured a standard eight-hour day. That same year street car workers organized a union; three weeks later the company, which also supplied electrical power to the community, fired the president of the union.

A federally-appointed conciliation board recommended the reinstatement of this individual. The company refused, and fired more than twenty additional workers, replacing them with non-union men. The union, which was popular with the public, went on strike. As one newspaper noted, the introduction by the company of outside strikebreakers created considerable ill will in the community and generated support from the longshoremen and the carpenters’ and joiners’ union. The protest began with nearly two hundred streetcar workers parading the streets with banners and a brass band.

Groups of boys and men began to block individual streetcars and a number of people were injured by stones and shattered glass. The mayor read the Riot Act; ironically a few blocks away in King Square citizens were enjoying a concert by the band of the 62nd Regiment, Saint John Fusiliers. A police officer fired several warning shots from his revolver, a rare occurrence in Saint John, but the crowed was undeterred.

As the mayor was ordering the crowd to disperse (which it refused to do), the striking street railway men arrived in parade formation from another part of town. Despite the reading of the Riot Act, the crowd in Market Square did not disperse and the civil authorities ordered in a small detachment of Royal Canadian Dragoons.

The mounted troops, who were posted at the local armoury as cavalry instructors, rode through a crowd that included women and children, striking people with the flats of their ceremonial swords. People were also injured by horses; the troops were pelted with bottles and rocks. According to one account, a woman had her skirt folded up to her knees, filled with rocks. In the fracas, a man was shot in the leg and a police detective was injured.

Angry members of the crowd attacked and overturned two trolleys at Market Square then vandalized the company's power plant on Dock Street (the modern St. Patrick Street), breaking windows, damaging machinery and chasing away the plant workers. This was all targeted violence-there was no general looting. For a time electric power to parts of the city was cut.

The press reported that the overturned cars were set on fire. A second attack, on the company’s street car barns on Wentworth Street, was driven back by Pinkerton and Thiel private detectives armed with rifles and shotguns. Most of the firing consisted of shots fired into the air, although some birdshot was discharged at attackers. According to most accounts, the strikers had not taken part in any violence. By dawn a sizeable militia force had been called out for duty. The 62nd Fusiliers were issued live ammunition and the cavalry troopers were given combat swords.

During the strike’s second day, municipal and provincial officials met with representatives of both sides. All saloon owners in the city agreed to close their premises during the crisis. The militia at first refused to escort streetcars driven by replacement workers, citing regulations. Then the militia had a change of heart.

In one street militiamen were on duty with fixed bayonets. On the second night, violence nearly erupted again when crowds surrounded several street cars, but the police kept things from getting out of hand. Despite being warned by the mayor that a curfew was in effect, people remained on the streets. The large militia force, stationed at five points across the city, did not have to be deployed.

The strike ended when the company agreed to rehire most of the men it had discharged. In the aftermath of the disorders, the press criticized the municipal police for failing to make sufficient arrests. This suggests that the police department sympathized with the strikers. Several young men were arrested, none of them apparently members of the union. According to Robert Babcock, the strike had been won not by the union, but by young men and boys who sympathized with the strikers, or who ay least did not like the company.

Petit-Rocher 1977: Villagers vs. Bikers

During the 1970s, with media revelations about the extent of organized crime in Canada, more attention was given to so-called outlaw motorcycle gangs, which according to the police were linked to drug trafficking and other criminal activity. The Maritime provinces had their own versions of these organizations, who sometimes hosted visiting bikers from Ontario and Quebec.

In one well-publicized incident, a group of intoxicated motorcyclists misbehaved on a dance cruise held on the Princess of Acadia ferry between Digby, N.S. and Saint John. They were met at the Saint John ferry terminal by a large force of police, which placed many of the bikers under arrest.

In 1977 residents of the small Acadian community of Petit-Rocher on the Bay of Chaleur in Gloucester county grew frustrated with the actions of a small motorcycle club known as the Dalton gang. The village of Petit-Rocher contained two thousand residents and a further three thousand lived in the surrounding area. Although the 'Daltons' numbered only eight and some of them were related to members of the community, residents felt the small RCMP detachment had not done enough to protect the community over a period of several years.

Until the dramatic events of 1977 no criminal charges had been laid against club members. In the wake of the 1977 events, the press described villagers living through "a reign of terror." That summer the residents struck back. The story was picked up by American media, which published headlines such as "Villagers Rout Cycle Gang."

After a fight at a Petit-Rocher bar during which one man had been seriously injured, tempers in the village flared. Five members of the club were taken into custody by the RCMP. The remaining members fled to their clubhouse on the outskirts of the village. A crowd of up to three hundred enraged locals converged on the site and burned down the clubhouse and two other buildings and destroyed five motorcycles and three other vehicles.

The RCMP managed to escort the eight female friends of the group to a place of safety. In the melee a dog belonging to the Daltons was killed. Gunfire was exchanged, the window of a police car was shot out and two officers were slightly wounded, one by bullet fragments. Two members of the Dalton gang fled into the woods where they remained for twenty four hours before surrendering to the police for their own protection. Although the police seized weapons at the scene, no other members of the community were charged.

The provincial court in Bathurst refused to release the seven bikers on bail, arguing that their freedom would endanger public safety. L’Evangeline, the province’s French language newspaper, described the events as a ‘war’ between the bikers and the villagers. The RCMP reported that Petit-Rocher had received many offers of help from around the Maritime region.

Comments to the press suggested that the RCMP, which on the national level has identified biker gangs as a menacing part of organized crime, was not totally displeased by the outcome. At the preliminary hearing Judge Frederic Arsenault objected to the use of the term ‘vigilante’ by the anglophone press to describe the events in Petit-Rocher, remarks which could be interpreted as a partial justification of the actions of the day. In the end, several members of the Daltons were charged with assault causing bodily harm and possessing a weapon dangerous to the public peace.

The Daltons probably took their name from a famous band of outlaws in the late 19th century American southwest. In a more dramatic and violent version of the events in New Brunswick, the original Dalton gang had met its demise at the hands of armed citizens during a bank robbery in Coffeyville, Kansas.

Burnt Church 1999-2001: A dispute over resources

Disputes over resources, jobs and the economic fate of communities, many of which depend on seasonal employment, are hardly unique to New Brunswick.

In addition to labour disputes, disagreements over fisheries policies in the Maritime provinces occasionally have turned violent. In 1979 for example, the RCMP used tear gas against demonstrators on the wharf at Caraquet where inshore fishers opposed the landing of herring from offshore seiners.

Earlier, more than two hundred inshore fishers had prevented the unloading of herring at Shippegan. Following this, the RCMP blocked the road to the Shippegan wharf so that seiners could unload their catch. On another occasion the RCMP fired tear gas at a crowd of woodcutters blocking the road near the Consolidated Bathurst pulp and paper mill and arrested three dozen demonstrators.

Disputes on the Acadian peninsula over the crab fishery in 1986, in which a police officer was injured, later convinced the RCMP to automatically deploy the heavily-armed Emergency Response Team when police tactical forces were called to demonstrations in the region.

The area also saw protests over health care cutbacks, the closing of a military base and changes to unemployment insurance. All of this produced policies that seemed to reflect an attitude by the provincial government and the RCMP (which performed provincial policing on contract) that northern New Brunswick was a 'problem' region.

Many of New Brunswick's First Nations communities suffer from unemployment, poverty and poor housing. In recent years they have been attempting become more self sufficient. In 1999 following a historic Supreme Court of Canada decision on Native fishing rights, R. v. Marshall, members of the Burnt Church First Nation on Miramichi Bay were optimistic that they could take part in the lucrative commercial lobster fishery.

In this quest they faced formidable obstacles. The events that transpired would become known as ‘New Brunswick’s Oka Crisis,’ and included vigilante activity by non-Native fishers, civil disobedience by Mi’kmaq and, in the opinion of many, an overreaction by the federal government authorities. The local Mi’kmaq interpreted the ruling as giving them a constitutional right to fish lobster out of season in order to earn a 'moderate livelihood.'

Non-native fishers feared that an unregulated native fishery would damage or even destroy local lobster stocks. First Nation fishers who attempted to exercise their right to harvesting faced threats and intimidation by established fishers and had lobster traps vandalized.

The Burnt Church First Nation was one of several in the region that refused to sign a fishing agreement with the federal Department of Fisheries and Oceans. Native leaders and their sympathizers protested that the authorities were not doing enough to protect the people of Burnt Church from intimidation and vandalism. In October, 1999 the RCMP charged twenty five non-natives with various offences. Ongoing negotiations between the federal government and native leaders were unproductive.

In 2000 the federal government, in response to a clarification from the Supreme Court of Canada, attempted to impose regulations on the Native fishery in the Maritime provinces. The authorities responded to continued fishing by Burnt Church aboriginals with a heavy RCMP presence and large numbers of Department of Fisheries and Oceans (DFO) officers in Miramichi Bay.

A series of raids resulted in the seizure of hundreds of lobster traps, the sinking of two fishing boats and a series of arrests, including of the band's chief. Television reporters filmed DFO boats deliberately swamping small boats containing Mi’kmaq fishers, knocking them into the water.

Many of the events were documented in a National Film Board documentary Is the Crown at War with Us? The crisis ended up costing the federal government millions of dollars. A government inquiry in 2002 recommended that criminal charges in a number of cases be dropped and that Native fishers should be compensated for damaged equipment.

Grand Manan 2006: Anxieties over drugs

The most recent prominent example of social violence in New Brunswick was a series of events of the summer of 2006, when anxieties over the sale and use of illegal drugs on this island of community of than three thousand boiled over into vigilante action. Grand Manan, located in the Bay of Fundy, is dominated by the fishery and the aquaculture industry.

During the summer months its population is augmented by tourists and seasonal residents. By the early 20th century, parents had grown increasingly concerned about the availability of illegal drugs such as crack cocaine, ecstasy and oxycontin. As at Petit-Rocher in 1977, the small local RCMP detachment was both blamed for contributing to the problem and overwhelmed by the ensuing violence. In the immediate aftermath, the RCMP increased its presence to seventy officers and added a helicopter and boat.

In 2006 a number of men on the island decided to drive an alleged drug dealer out of the small community of Castalia. Community anxieties over drug and alcohol use were high partly because of the recent deaths of a number of young men. Tensions mounted and at one point a vehicle parked on the property of the alleged crack cocaine dealer was set on fire.

This individual was a non-islander. On the night in question, a crowd of forty or fifty residents, armed with bats, knives and guns, gathered to intimidate several people inside the home of the suspected dealer. After a rifle was discharged at the crowd, a rifle and a flare gun were fired in retaliation.

According to some media reports RCMP officers on the scene were not harmed, but other accounts suggested that rocks were thrown. During the four-hour incident members of the crowd set fire to the residence and used a truck as well as women locking arms to block volunteer fire fighters from extinguishing the blaze. Two men were allegedly beaten and the occupants of the house were escorted off the island for their own safety.

Residents resented the heavy police presence after the incident, and accused the RCMP of protecting criminals. The police eventually charged the 'Grand Manan Five,' whom many regarded as heroes, with arson, dangerous use of firearms and improper storage of firearms.

The community rallied with food and other assistance for the families of the arrested men, who were all in their 20s or early 30s. A legal defence fund collected $20,000. Their lawyer argued that they were not vigilantes but had simply acted in self defence. Four were convicted by jury and one acquitted. The sentences included house arrest and probation and two of those convicted were ordered to pay compensation for the burned building. The alleged drug dealer, who also was charged with various offences, ended up leaving the island.

In the aftermath of these events the federal and provincial governments responded with investments in the community, including a youth centre and an outdoor skating rink. The incident received wide media coverage and was much discussed within New Brunswick and beyond. It also inspired a song called "The Boys" by a New Brunswick country music group.

David G. Bell, Early Loyalist Saint John: The Origins of New Brunswick Politics, 1783-1786 (Fredericton: New Ireland Press, 1983).

Commission for Public Complaints Against the RCMP, Chair’s Interim Report-Events in Saint-Saveur and Saint-Simon, New Brunswick, March 28, 2000, available online at: http://www.cpc-cpp.gc.ca/prr/rep/pii/St-Simon/In